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Cooperative Management Act two years ago, you placed great emphasis on the need for the states 

 and the federal government to work together in partnership with the Regional Fishery Management 

 Councils. The states and the Commission have and continue to be committed to this partnership. 

 In this instance, however, the federal government has chosen to announce a major change to the 

 institutional way in which we address management of a major species without first having talked to 

 its parmers, or even given them fair notice. This is no way to conduct a partnership. 



The timing of this proposed action is unfortunate. The Commission and the Mid- Atlantic 

 Council have been working hard on a major amendment to the FMP for Bluefish. It is essential 

 that we proceed with completing this action this year. The resource as well as commercial and 

 recreational fishermen deserve an up-to-date management program. The credibility of the fisheries 

 management process - state, federal and cooperative - depends upon it. The Mid- Atlantic Council 

 staff has the lead in undertaking this work on behalf of the state and federal partners involved in the 

 program. Now, however, the Council's authority is in question. It would be a grave error if this 

 ill-considered action delayed necessary progress in expeditiously completing Amendment 1 

 according to schedule. 



If together the states and the federal agencies determine that the lead responsibility for 

 managing bluefish should be exercised by the states under the Atlantic Coastal Fisheries 

 Cooperative Management Act, the Atlantic States Marine Fisheries Commission will do what it can 

 to proceed as expeditiously as possible according to its procedures, including public comment. 

 However, this would require a level of effort that the Commission has not included in its activity 

 planning for this year, and could delay the development of other critical coastal fishery 

 management programs. 



Mr. Chairman, the states and the National Marine Fisheries Service have worked hard to 

 improve upon a close and productive working over the past few years. We can only assume that 

 the impetus for this proposal is coming from elsewhere in the Administration. The manner in 

 which this has been handled indicates insensitivity to the partnership nature of cooperative fisheries 

 management plaiming; and could delay important action to amend the FMP for Bluefish. The 

 states and the federal agencies need to work faithfully together to ensure that these unfortunate 

 results do not occur. That being said, the Atlantic States Marine Fisheries Commission will 

 comment on the substance of the proposal when it is published for comment. 



DRAFT:Testimony of John H. Dunnigan April I, 1996 



Subcommittee on Fisheries, Wildlife and Oceans page 7 



